20090406IPC to Staff 1.pdf

DONOVAN E. WALKER
Corporate Counsel
esIDA~POR~
An IDACORP Company
April 6, 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-09-06
FCA
Dear Ms. Jewell:
Enclosed for filing please find an original and three (3) copies of Idaho Power
Company's Response to the First Production Request of the Commission Staff to Idaho
Power Company in the above matter.
Very Iy yours,ç;cJaL
Donovan E. Walker
DEW:csb
Enclosures
P.O. Box 70 (83707)
1221 W. Idaho St.
Boise, ID 83702
DONOVAN E. WALKER (ISB No. 5921)
BARTON L. KLINE (ISB No. 1526)
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: 208-338-6936
dwalker(âidahopower.com
bkline(âidahopower.com
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2009 APR -6 PH 12: 32
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 THE APPLICATION )
OF IDAHO POWER COMPANY FOR ) CASE NO. IPC-E-09-06
AUTHORITY TO IMPLEMENT FIXED )
COST ADJUSTMENT ("FCA") RATES ) IDAHO POWER COMPANY'S
FOR ELECTRIC SERVICE FROM JUNE 1, ) RESPONSE TO THE FIRST
2009, THROUGH MAY 31,2010. ) PRODUCTION REQUEST OF THE
) COMMISSION STAFF TO IDAHO
) POWER COMPANY
COMES NOW, Idaho Power Company ("Idaho Power" or "the Company"), and in
response to the First Production Request of the Commission Staff to Idaho Power
Company dated March 27,2009, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1
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.
RESPONSE TO REQUEST NO.1: The Company has not conducted any formal
analyses or held internal discussions specifically related to the causes of the decreases
seen in 2008 average kilowatt-hour usages per customer. Several factors are likely to
have contributed to the reduction, including, but not limited to, electric and gas prices,
demand-side management programs, demand-side management education, public
awareness of demand-side management and green initiatives, recent changes to
building codes, and the current state of the economy.
The response to this Request was prepared by Scott Sparks, Senior Pricing
Analyst, Idaho Power Company, in consultation with Donovan E. Walker, Corporate
Counsel, Idaho Power Company.
DATED at Boise, Idaho, this 6th day of April 2009.
tJwt~
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 6th day of April 2009 I served a true and correct
copy of the IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY upon the
following named parties by the method indicated below, and addressed to the following:
Commission Staff
Kristine A. Sasser
Deputy Attomey General
Idaho Public Utilities Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
-. Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-. Email Kris.sasser(âpuc.idaho.gov
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Donovan E. Walker
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3