20110505ICIP 1-2 to IPC.pdf

Peter J. Richardson ISB # 3195
Gregory M. Adams ISB # 7454
RICHARDSON & O'LEARY PLLC
515 N. 27th Street
Boise, Idao 83702
Telephone: [phone]
Fax: [phone]
petercmrichardsonandolear.com
greg~chardsonandolear.com
RECE\VED
2ßH MAY -4 PM 4: 44
Attorneys for the Industral Customers of Idaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMSSION
IN TH MATTER OF APPLICATION OF
IDAHO POWER COMPANY FOR
AUTHORITY TO IMLEMENT POWER
COST ADJUSTMENT ("PCA") RATES
FOR ELECTRIC SERVICE FROM JU
1,2011 THROUGH MAY 31, 2012
) CASE NO. IPC-E-ii-06
) FIRST PRODUCTION REQUEST OF
) THE INDUSTRIAL CUSTOMERS OF
) IDAHO POWER
)
)
Pursuat to Rule 225 of the Rules of Procedure of the Idaho Public Utilties Commission
(the "Commission"), the Industral Customers ofIdaho Power ("ICIP") hereby requests that
Idao Power Company ("Idaho Power") provide responses to the following with supporting
documents, where applicable, as soon as possible.
Ths production request is to be considered as continuig, and the Idaho Power is
requested to provide by way of supplementar responses additional documents that it or any
person acting on its behalf may later obtan that will augment the responses or documents
produced.
Please provide one physical copy and one electronic copy, if available, of your answer to
Mr. Adams at the address noted above. Please provide an additional electronic copy, or if
Page 1 - FIRST PRODUCTION REQUEST OF THE INUSTR
CUSTOMERS OF IDAHO POWER - IPC-E-II-06
unavailable a physical copy, to Dr. Don Reading at: 6070 Hil Road, Boise, Idao 83703, Tel:
[phone]; Fax: [phone]; dreading(Ðmidspring.com.
For each item, please indicate the name of the person(s) preparng the answers, along
with the job title of such person(s) and the witness at hearng who can sponsor the answer.
Some of the following requests may include disclosures deemed by Idao Power to be
confdentiaL. Counsel for the Industral Customers of Idao Power contacted 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 Idaho Power ar prepared to sign
any such agreement to obtain the materials relevant to ths proceeding, and expect tht executing
such a confdentiality agreement will not delay Idaho Power's responses to these Requests for
Production.
Page 2 - FIRST PRODUCTION REQUEST OF THE INUSTRIL
CUSTOMERS OF IDAHO POWER- IPC-E-II-06
REOUEST FOR PRODUCTION NO.1
Please provide in electronic formt Exhbits 1,2, and 3 that were par of Mattew T. Larkin's
Direct Testiony filed in ths docket.
REQUEST FOR PRODUCTION NO.2
Please provide all documents, workpapers, and electronic spreadsheet that have been provided to
the Idao Public Commission Staf in Case No. IPC-E-II-06 including the Company's
Responses to the Commission's Sta audit request.
Th you for your prompt attention to ths First Request for Production.
~IY~
dams
SON & O'LEARY, PLLC
Page 3 - FIRST PRODUCTION REQUEST OF THE INDUSTRI
CUSTOMERS OF IDAHO POWER - IPC-E-II-06
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 4th day of May, 2011, a tre and correct copy of the
within and foregoing FIRST PRODUCTION REQUEST OF THE INDUSTRIL CUSTOMERS OF
IDAHO POWER IN CASE NO.IPC-E-II-06 was served in the maner shown to:
Ms. Jean Jewell
Coi:ssion Secta
Idao Public Utilities Commssion
POBox 83720
Boise, il 83720-0074
X Hand Delivery
_ U.S. Mail, postage pre-paid
Facsimile
Electronic Mail
Donovan Walker
Jason B Wiliams
Idao Power Company
POBox 70
Boise, Idaho 83707-0070
dwaiker~idahopower.com
jwil1ams~idahopower.com
_ Hand Delivery
X U.S. Mail, postae pre-paid
Facsimile
Electronic Mail
Matthew T. Larkin
Gregory W. Said
Idaho Power Company
POBox 70
Boise, Idaho 83707-0070
dnemnich~idahopower.com
gsaidcmidaopower.com
_ Hand Delivery
XU.S. Mail, postage pre-paid
Facsimile
Electronic Mail
~(\i
Nina Curis
Adminstrative Assistat