20090806ICIP to IPC 42-46.pdf

Peter J. Richardson ISB # 3195
RICHARDSON & O'LEARY PLLC
515 N. 27th Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter(Ðrichardsonandoleary.com
RECEIVED
209 AUG -6 PHS: 49
IDAHO PUBLIC
UTILITIES COMMiSSION
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 A CERTIFICATE OF
PUBLIC CONVENIENCE AND
NECESSITY FOR THE LANGLEY
GULCH POWER PLANT
) CASE NO. IPC-E-09-03
)
) THIRD PRODUCTION REQUEST OF
) THE INDUSTIAL CUSTOMERS OF
) IDAHO POWER
)
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), The Industrial Customers ofIdaho Power ("ICIP") by and through their
attorney of record, Peter J. Richardson, hereby requests that Idaho Power Company
("Company") provide the following documents.
This production request is to be considered as continuing, and the Company is requested
to provide by way of supplementary 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
unavailable a physical copy, to Dr. Don Reading at: 6070 Hil Road, Boise, Idaho 83703, Tel:
[phone]; Fax: [phone]; dreading(Ðmindspring.com
1 -THIRD PRODUCTION REQUEST OF INDUSTRIL CUSTOMERS OF IDAHO POWER - IPC-E-09-03
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.
Some of the following requests may include disclosures deemed by Idaho Power to be
confidentiaL. 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 Commission on July 16
and 23,2008 the Protective Agreement in connection with this case IPC-E-08-10.
The following questions are related to the updated economic forecast the Company will
be filing with the Commission in August. Please provide your answers contemporaneously with
that fiing.
REQUEST FOR PRODUCTION NO. 42:
Please provide, in electronic format if possible, all data input fies used in constructing
the forecast for each customer class, along with an explanation of each variable used.
REQUEST FOR PRODUCTION NO. 43:
Please provide the source of each input varable used in constructing the forecast.
REQUEST FOR PRODUCTION NO. 44:
Please provide, in electronic format if possible, all work papers used in deriving the
input values used in the forecast for each customer class.
REQUEST FOR PRODUCTION NO. 45:
Please provide, in electronic format if possible, all formulas and algorithms used in
constructing the forecast for each customer class, along with an explanation of each formula or
algorithms used.
2 -THIRD PRODUCTION REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO POWER - IPC-E~09~03
REQUEST FOR PRODUCTION NO. 46:
Please provide, in electronic format if possible, the output values found in the forecast
for each customer class along with an explanation of each output value.
DATED this 6th day of August, 2009.
RICHARDSON & O'LEARY PLLC
By: ~.e,
Peter J. Richardson, ISB #3195
Attorneys THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER
3 -THIRD PRODUCTION REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO POWER - IPC-E-09-03
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 6th day of August, 2009, a true and correct copy of the
within and foregoing THIRD PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER was served in the maner shown to:
Ms. Jean Jewell (C)
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington (83702)
PO Box 83720
Boise, ID 83720-0074
X- Hand Delivery
_U.S. Mail, postage pre-paid
Facsimile
Electronic Mail
Lisa Nordstrom (C)
Baron L. Kline
Idaho Power Company
PO Box 70
Boise, Idaho 83707-0070
Inordstrom(fidahopower .com
bkline(fidahopower .com
X- Hand Delivery
_U.S. Mail, postage pre-paid
Facsimile
Electronic Mail
Scott Woodbur (C)
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington
Boise ID 83702
Scott. woodbury(fpuc.idaho. gov
L Hand Delivery
_U.S. Mail, postage pre-paid
Facsimile
Electronic Mail
Dean J. Miler (C)
McDevitt & Miler LLP
420 W. Banock St (83702)
PO Box 2564
Boise ID 83701
joe(fmcdevittmiler .com
_ Hand Delivery
iU.S. Mail, postage pre-paid
Facsimile
Electronic Mail
Wiliam Borders (C)
Assistant General Counsel
Invenergy Thermal Development LLC
One South Wacker Dr., Suite 1900
Chicago, IL 60606
wborders(finvenergyllc.com
_ Hand Delivery
iU.S. Mail, postage pre-paid
Facsimile
Electronic Mail
4 -THIRD PRODUCTION REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO POWER - IPC-E-09-03
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey, Chtd.
201 E. Center
PO Box 1391
Pocatello,ID 83204-1391
elo(ßacinelaw.net
Anthony Yanel
29814 Lake Road
Bay Vilage, OH 44140
tönyCiankel.net
Ken Miler
Clean Energy Program Director
Snake River Allance
PO Box 1731
Boise, ID 83701
kmiler(fsnakeriverallance.org
Betsy Bridge
Idaho Conservation League
710 North Sixth Street (83702)
PO Box 844
Boise, ID 83701
bbridge(fwildidaho.org
~úwtiJ
Nina Curis
Administrative Assistant
_ Hand Delivery
iU.S. Mail, postage pre-paid
Facsimile
Electronic Mail
_ Hand Delivery
iU.S. Mail, postage pre-paid
Facsimile
Electronic Mail
_ Hand Delivery
iU.S. Mail, postage pre-paid
Facsimile
Electronic Mail
_ Hand Delivery
iU.S. Mail, postage pre-paid
Facsimile
Electronic Mail
5 -THIRD PRODUCTION REQUEST OF INUSTRIAL CUSTOMERS OF IDAHO POWER - IPC-E-09-03