20100217Staff 3-5 to IPC.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 1895
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ZOIOFEB 17 PM 4: 10
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF APPLICATION OF )
IDAHO POWER COMPANY TO ESTABLISH )
ITS BASE LEVEL FOR NET POWER SUPPLY )EXPENSES FOR 2010. )
)
)
)
)
CASE NO. IPC-E-I0-0l
THIRD 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,
Scott Woodbury, Deputy Attorney General, requests that Idaho Power Company (Company;
IPC) provide the following documents and information as soon as possible, but no later than
MONDAY, MARCH 1,2010.
This Production Request is to be considered as continuing, and Idaho Power 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.
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 who can sponsor the answer at hearing.
Please provide answers to each question, 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
THIRD PRODUCTION REQUEST TO
IDAHO POWER COMPANY 1 FEBRUARY 17,2010
person preparing the document, and the name, location and phone number of the record 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.3: Please provide an analysis showing the curent all-in cost of coal for
Bridger by coal source (i.e. Bridger coal, Black Butte coal, market, etc.)
REQUEST NO.4: Please provide all cost/enefit criteria and analyses showing that the
coal purchased for Bridger is at the lower cost or market.
REQUEST NO.5: Please provide analysis, documentation, or reports comparing the
costs and benefits of water to be leased from the ShoBan Tribe in 2010.
DATED at Boise, Idaho, this 17liy of Februar 2010.
"Scott Wood ur
Deputy Attorney General
Technical Staff: Terri Carlock/3-4
Rick Sterling/5
i:umisc:prodreq/ipce i 0.0 i swrpstc ¡pc3
THIRD PRODUCTION REQUEST TO
IDAHO POWER COMPANY 2 FEBRUARY 17,2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 17TH DAY OF FEBRUARY 2010,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
IPC-E-IO-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
BARTON L KLINE
LISA D NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: bkline(fidahopower.com
Inordstrom(fidahopower.com
PETER J RICHARDSON
GREGORY ADAMS
RICHARDSON & O'LEARY
PO BOX 7218
BOISE ID 83702
E-MAIL: peter(frichardsonandoleary.com
greg(frichardsonandoleary. com
GREGORY W SAID
DIRECTOR OF STATE REGULATION
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: gsaid(fidahopower.com
DR. DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dreading(fmindspring.com
Jo~
SECRETAR
CERTIFICATE OF SERVICE