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Home My WebLink About20090624IPC 6-7 to ICIP.pdfesIDA~PO(I An IDACORP Company BARTON L. KLINE Lead Counsel \0;\\10 pl U11\.rT\ES CO~ June 24, 2009 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-09-03 LANGLEY GULCH POWER PLANT Dear Ms. Jewell: Enclosed for filing are an original and three (3) copies of Idaho Power Company's Third Production Request to the Industrial Customers of Idaho Power in the above matter.verg~ Barton L. Kline BLK:csb Enclosures P.O. Box 70 (83707) 1221 W. Idaho St. Boise, ID 83702 BARTON L. KLINE, ISB #1526 LISA D. NORDSTROM, ISB #5733 Idaho Power Company P.O. Box 70 Boise, Idaho 83707 Telephone: 208-388-2682 Facsimile: 208-388-6936 bklineCâidahopower.com InordstromCâidahopower.com RECE\VED iOOq JUN 24 M~ lOt S2 U1\(Rtt~ iÓWh\~$\ON 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 MATTER OF IDAHO POWER COMPANY'S APPLICATION FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY FOR THE LANGLEY GULCH POWER PLANT. ) ) CASE NO. IPC-E-09-03 ) ) IDAHO POWER COMPANY'S ) THIRD PRODUCTION REQUEST ) TO THE INDUSTRIAL ) CUSTOMERS OF IDAHO POWER ) COMES NOW, Idaho Power Company ("Idaho Powet' or "the Company"), by and through its attorneys, and hereby requests that the Industrial Customers of Idaho Power ("ICIP") answer the following production requests and provide the following information and documents in accordance with the Commission's Rules of Procedure and applicable scheduling orders and notices issued by the Commission in this proceeding. IDAHO POWER COMPANY'S THIRD PRODUCTION REQUEST TO THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 1 To allow the Company to utilze the response in preparing its rebuttal testimony, it is necessary that the response to the production requests be provided as soon as possible, but no later than June 30, 2009. This production request is to be deemed continuing in nature and ICIP is requested to provide, through supplementation, additional documents, etc., information that is responsive to this request that it or any person acting on its behalf may later come into possession or become aware of. REQUEST NO.6: On page 20 of ICIP witness Mitchell's testimony, she presents Figure 8, entitled "Idaho Per Capita Personal Income IPC August 2007 and DFM April 2009 Forecasts." On line 4 below the chart, Ms. Mitchell identifies the source of the data used to prepare Figure 8 as the "IPC IRP 2008 Update and Idaho Economic Forecast Quarterly Detail, April 2009." Please provide a specific reference to the location in the Company's 2008 Integrated Resource Plan Update from which the data used to prepare Figure 8 was taken. Please provide either a specific reference to the location(s) in the 2008 Integrated Resource Plan Update, copies of the specific pages from the document that is cited as the source of the "IPC August 2007" data, or specific directions to electronically access the data used. The information provided in response to this Request should specifically identify the location of the source data used to plot the "diamond" (IPC) line on Figure 8. REQUEST NO.7: On page 21 of ICIP witness Mitchell's testimony, she presents Figure 10, entitled "Idaho Total Employment: IPC August 2007 and DFMApril 2009 Forecasts." Ms. Mitchell identifies the source of the data used to prepare the chart as the "IPC IRP 2008 Update and the Idaho Economic Forecast Quarterly Detail, April IDAHO POWER COMPANY'S THIRD PRODUCTION REQUEST TO THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 2 2009." Please provide a specific reference to the location in the Company's 2008 Integrated Resource Plan Update from which the data used to prepare Figure 10 was taken. Please provide either a specific reference to the location( s) in the 2008 Integrated Resource Plan Update, copies of the specific pages from the document that is cited as the source of the "IPC August 2007" data, or specific directions to electronically access the data used. The information provided in response to this Request should specifically identify the location of the source data used to plot the "diamond" (lPC) line on Figure 10. DATED at Boise, Idaho, this 24th day of June 2009. i ! ii, Vt BARTON L. KLINE Attorney for Idaho Power Company ( IDAHO POWER COMPANY'S THIRD PRODUCTION REQUEST TO THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 24th day of June 2009 I served a true and correct copy of IDAHO POWER COMPANY'S THIRD PRODUCTION REQUEST TO THE INDUSTRIAL CUSTOMERS OF IDAHO POWER upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Scott Woodbury Deputy Attorney General Idaho Public Utilities Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 Industrial Customers of Idaho Power and Northwest and Intermountain Power Producers Coalition 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 Hill Road Boise, Idaho 83703 Snake River Allance Ken Miller Snake River Allance P.O. Box 1731 Boise, Idaho 83701 Idaho Irrigation Pumpers Association, Inc. Eric L. Olsen RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED P.O. Box 1391 201 East Center Pocatello, Idaho 83204-1391 -- Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email Scott.WoodburyCâpuc.idaho.gov Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email peterCârichardsonandoleary.com Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email dreadingCâmindspring.com Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email kmilerCâsnakeriveralliance.org Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email eloCâracinelaw.net IDAHO POWER COMPANY'S THIRD PRODUCTION REQUEST TO THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 4 Anthony Yankel Yankel & Associates, Inc. 29814 Lake Road Bay Vilage, Ohio 44140 Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email tonyCâyankel.net Idaho Conservation League Betsy Bridge Idaho Conservation League 710 North Sixth Street P.O. Box 844 Boise, Idaho 83701 Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email bbridgeCâwildidaho.org Northwest and Intermountain Power Producers Coalition Susan K. Ackerman 9883 NW Nottage Drive Portland, Oregon 97229 Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email Susan.k.ackermanCâcomcast.net Community Action Partnership Association Of Idaho Brad M. Purdy Attorney at Law 2019 North 1 ih Street Boise, Idaho 83702 Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email bmpurdyCâhotmail.com (1tQBarton L. Kline '\-. IDAHO POWER COMPANY'S THIRD PRODUCTION REQUEST TO THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 5