The URL can be used to link to this page

Home My WebLink About20100217ICIP 11-12 to IPC.pdf2010 FEB l 7 AM 8= I 3_r.~~PI ATTORNEYS AT LAW Tel: 208-938-7900 Fax: 208-938-7904 P.O. Box 7218 Boise, ID 83707 - 515 N. 27th St. Boise, ID 83702 ncr;-" ,,''' ... ,,,1 ;: ~ 1.~ 16 February 2010 Ms. Jean Jewell Commission Secretary Idaho Public Utilties Commission 472 W. Washington Boise, ID 83702 RE: IPC-E-10-01 Dear Ms. Jewell: We are enclosing three (3) copies of the SECOND PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER in the above case. The original has been delivered to Idaho Power Company. An additional copy is enclosed for you to stamp for our records. Sincerely,~ ÚJ~\ Nina Curtis Richardson & O'Leary PLLC Peter J. Riqhads ISB # 3195 Grgory M. Adas ISB # 7454 RICHAON & O'LEARY PLLC 515 N. 27m Street Boise, Ida 83702 Telephone: (208) 938-2236 Fax: (208) 938-7904 r-ç\...l.. ZOW FEB 17 AM 8= l 3 .com Attornys fo th Indutral Customers of Idaho Power BEORE THE IDAHO PUBLIC UTILITIES COMMISSION ¡lNTIMA1'ROFmE ) CASENO.IPC..E-lO-Ol AP~LIÇATl9N OfJ¡)AlO P()yvR ) CÔMPANY TO ESTABLISH ITS ) SECOND PRODUCTION REQUEST BASE LEVEL FOR NET POWER SUPPLY) OF THE INUSTRIAL CUSTOMERS EXPENSES FOR 2010. ) OF IDAHO POWER ) Puruat to Rule 225 of the Rules of Procedure of the Idao Public Utilities Conussion (the "Comission"), the Industral Customers of Idao Power ("ICIP") hereby requests that Idao Powèr Company C"Idaho Power") provide responses to the following with supporting documents, where applicable. Ths production reuest is to be considered as contiuig, and the Idao Power is requested to provide by way of supplementa responses additional documents that it or any person actig on its behalf may later obta that will augment the responses or documents produced. Pl~se provide one physical copy and one electronic copy, if available, of your answer to Mr. Ada at the address noted above. Please provide an additiona electronic copy, or if Page 1 - SECOND PRODUCTION REQUEST OF TH INDUSTRL CUSTOMERS OF IDAHO POWER - IPC-E-10-01 unavailable a physical copy, to Dr. Don Reading at: 6070 Hil Road, Boise,Jdah08370?, Tel: (208) 342-1700; Fax: (208) 384-1511; dreading~mindspring.com. For each item, please indicate the name of the person(s) preparing theanswer~,Çtong with the job title of such person(s) and the witness at hearng who can sponsôr'te:aner. Some of the following requests may include disclosures deemed by Idaho Pnw-er to be confdential. Counsel for the Industral Customers of Idao Power contated counel for Idaho Power regarding a confidentiality agreement prior to sending these Requests for Production. Counsel and the expert witness of the Industral Customers of Idao Power are prepard to sign any such agreement to obtan the materials relevant to ths proceedg, and expect th executig such a confdentialty agreement will not delay Idaho Power's responses to these Reqpests for Production. Page 2 - SECOND PRODUCTION REQUEST OF TH INDUSTRI CUSTOMERS OF IDAHO POWER - IPC-E-1 0-0 1 REOUESTFOR PRODUCTION NO.Il As a follow up to ICIP's production request no. 4, please provide the entie contract(s) for the sae of coal from Bridger Coal Company to fuel the Bridger coal plant effective afer December 31, 2009. Ths request refers to the "newly negotiated agreements staring in 2010" discussed on page 9 ofStott Wright's dirct testimony in ths docket. If there is no wrtten contract, pleas explain all terms of 'te newly negotiated agreement(s), including the prices and the date the paries entered into the new agreement. ßEOUESTFOR PRODUCTION NO. 12 Did Idaho Power or PacifiCorp consider ceasing the purchase of surface-mined coal from Bridger Co..l Company afer the period of historically low cost coal ended "due to long-term coal supply conttacts tht expire(d) at the end of 2009," as discussed on page 9 of Scott Wright's direct testiniony in this docket? Please explain what steps the utilties took to evaluate the cost- effectiveness and/or feasibilty of purchasing coal from an alternative, non-affliate supplier when the lopg term contracts ended after 2009. If the utilities took no steps to conduct such an evaluation, please explai why. Than you for your prompt attntion to this Second Request for Production. 2.f~//tJ Date Page 3 - SE(tOND PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER- IPC-E-10-01 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 16th day of Febru, 2010, a tre and correct copy of the withn and fortgoing SECOND PRODUCTION REQUEST OF TH INDUSTRIAL CUSTOMERS OF IDAHO POWER COMPANY was served in the maner shown to: Ms. Jean Jewell Coniion Seeta Idao Public Utlities Commssion PO Box 83720 Boise, ID 83720..0074 _ Hand Delivery ~X_ U.S. Mail, postage pre-paid Facsimile Electronic Mail Lisa Nordstrom Baron L. Kline Idao Power Company PO Box 70 Boise, Idao 83707-0070 11)rdsm~oPQwer.com bkineaìidaQPQwer.côm Gregory W. Said Idao Power Company POBox 70 Boise, Idaho 83707-0070 gsadaìidsoP.wer.com X- Hand Delivery _U.S. Mail, postage pre-paid Facsimile Electronic Mail L Hand Delivery _U.S. Mail, postage pre-paid Facsimile Electronic Mail ~~~\ in CUrs Administrtive Assistant