20110411IPC Errata to Staff 2.pdf

LISA D. NORDSTROM
Lead Counsel
InordstromCâidahopower.com
eslDA~POR~
An IDACORP Company
April 11, 2011
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilties Commission
472 West Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-11-04
IN THE MATTER OF THE APPLICA TlON OF IDAHO POWER COMPANY
TO INCREASE ITS RATES FOR ELECTRIC SERVICE TO RECOVER ITS
2010 PENSION CASH CONTRIBUTION
Dear Ms. Jewell:
Enclosed for filing please find an original and three (3) copies of Idaho Power
Company's Errata to Its Response to the First Production Request of the Commission Staff
to Idaho Power Company in the above matter.
If you have any questions about the enclosed document, please do not hesitate to
contact me.
Very truly yours,
~--1!.7C~
Lisa D. Nordstrom
LDN:csb
Enclosures
1221 W. Idaho St. (83702)
P.O. Box 70
Boise, ID 83707
LISA D. NORDSTROM (ISB No. 5733)
DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
Inordstrom((idahopower.com
dwalker((idahopower.com
Attorneys for Idaho Power Company
Street Address for Express Mail:
1221 West Idaho Street
Boise, Idaho 83702
RECEIVED
lOll APR /I PM 12: l 8
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY TO )
INCREASE ITS RATES FOR ELECTRIC )
SERVICE TO RECOVER ITS 2010 )
PENSION CASH CONTRIBUTION. )
)
)
)
)
CASE NO. IPC-E-11-04
IDAHO POWER COMPANY'S
ERRATA TO ITS RESPONSE TO
THE FIRST PRODUCTION
REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER
COMPANY
COMES NOW, Idaho Power Company ("Idaho Powet') and corrects its response
to the First Production Request of the Commission Staff to Idaho Power Company
dated March 17, 2011, as follows:
IDAHO POWER COMPANY'S ERRATA TO ITS RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1
REQUEST NO.2: Mr. Anderson's direct testimony states that "The Company
assessed the appropriate amount to contribute in 2010 by modeling alternative funding
scenarios and projecting their impacts on expected funding levels, short and medium-
term funding requirements, and PBGC premiums." Please provide copies of all models
and analysis used to determine the appropriate amount to contribute.
RESPONSE TO REQUEST NO.2: The first sentence of the first full paragraph
found on page 4 of Idaho Powets response provided on April 7, 2011, reads as follows:
Also included on the enclosed confidential CD is an e-mail
sent by Robert Schmidt from Millman to Steve Keen
providing Millman's estimate of the minimum amount Idaho
Power would need to contribute . . . .
However, the confidential information was not provided on a confidential CD; it
was provided as a hard copy to those parties that signed the Protective Agreement.
Therefore, the first sentence of the first full paragraph found on page 4 of Idaho
Powets response provided on April 7, 2011, should read as follows:
Also attached to this response is an e-mail sent by Robert
Schmidt from Miliman to Steve Keen providing Miliman's
estimate of the minimum amount Idaho Power would need to
contribute . . . .
The errata to Idaho Powets April 7, 2011, response was prepared by Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
DATED at Boise, Idaho, this 11 th day of April 2011.
£Q~LISA D. NORDST M
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S ERRATA TO ITS RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 11th day of April 2011 I served a true and
correct copy of IDAHO POWER COMPANY'S ERRATA TO ITS 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
Weldon B. Stutzman
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
-X Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-X Email Weldon.Stutzman((puc.idaho.gov
Industrial Customers of Idaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON & O'LEARY, PLLC
515 North 27th Street
P.O. Box 7218
Boise, Idaho 83702
Hand Delivered
-X U.S. Mail
_ Overnight Mail
FAX
-X Email peter((richardsonandolearv.com
greg((richardsonandoleary.com
Dr. Don Reading
Ben Johnson Associates
6070 Hil Road
Boise, Idaho 83703
Hand Delivered
-X U.S. Mail
_ Overnight Mail
FAX
-X Email dreading((mindspring.com
¿£i1.~
Lisa D. Nordst
IDAHO POWER COMPANY'S ERRATA TO ITS RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3