20090327Staff 1 to IPC.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6618
CEI\l"
LU09 M'IR 2 7 Pl'~ 2= I 0
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR )
AUTHORITY TO IMPLEMENT FIXED-COST )
ADJUSTMENT (FCA) RATES FOR )
ELECTRIC SERVICE FROM JUNE 1, 2009 )
THROUGH MAY 31, 2010. )
)
)
CASE NO. IPC-E-09-6
FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF
TO IDAHO POWER COMPANY
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Kristine A. Sasser, Deputy Attorney General, requests that Idaho Power Company (Company;
Idaho Power) provide the following documents and information on or before MONDAY,
APRIL 6, 2009.
This Production Request is to be considered as continuing, and Idaho Power is requested
to provide, by way of supplementary responses, additional documents that it or any person acting
on its behalf may later obtain that wil augment the documents produced.
Please provide answers to each question and any supporting workpapers that provide
detail or are the source of information used in calculations. The Company is reminded that
responses pursuant to Commission Rules of Procedure must include the name and phone number
of the person preparing the document, and the name, location and phone number of the record
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 MARCH 27, 2009
holder and if different the witness who can sponsor the answer at hearing if need be. Reference
IDAPA 31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic fies on CD with formulas activated.
REQUEST NO.1: Please provide all Idaho Power evidence, analyses and internal
communications discussing, explaining or quantifying circumstances that caused or may have
caused decreases in average kilowatt-hour usages per customer in 2008.
Dated at Boise, Idaho, this -i~ day of March 2009.
~,a'~1A
Kri me A. Sasser
Deputy Attorney General
Technical Staff: Lynn Anderson
i:umisc:prodreqlipce09.6ksla pr i .doc
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 MARCH 27, 2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 27TH DAY OF MARCH 2009,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-09-6,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DONOV AN E WALKER
BARTON L KLINE
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: dwalker(ßidahopower.com
bkline(ßidahopower .com
SCOTT D SPARKS
JOHN R GALE
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: ssparks(ßidahopower.com
rgale(ßidahopower.com
~;:.~.SECRETARY
CERTIFICATE OF SERVICE