HomeMy WebLinkAbout20110519IPC to ICIP 1-2.pdfDONOVAN E. WALKER
Lead Counsel
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An IDACORP Company
May 18, 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-11-06
IN THE MATTER OF THE APPLICA TlON OF IDAHO POWER COMPANY \
FOR AUTHORITY TO IMPLEMENT POWER COST ADJUSTMENT ("PCA')
RATES FOR ELECTRIC SERVICE FROM JUNE 1, 2011, THROUGH MAY
31, 2012
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 Industrial Customers of Idaho
Power in the above matter. Also enclosed are four (4) copies of a non-confidential disk
containing documents responsive to the aforementioned production request.
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Donovan E. Walker
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Enclosures
1221 W. Idaho St. (83702)
P.O. Box 70
Boise. ID 83707
DONOVAN E. WALKER (ISB No. 5921)
JASON B. WILLIAMS
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: (208) 388-5317
Facsimile: (208) 388-6936
dwalkercæidahopower.com
jwilliams(qidahopower.com
RECEtVED
iou MAY' 8 PM 4: 52
I (Ji\rl()UTlt.lrIES'
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR )
AUTHORITY TO IMPLEMENT POWER )
COST ADJUSTMENT ("PCA") RATES )
FOR ELECTRIC SERVICE FROM JUNE )
1,2011, THROUGH MAY 31,2012. )
)
)
)
CASE NO. IPC-E-11-06
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF
IDAHO POWER
COMES NOW, Idaho Power Company ("Idaho Powet' or "Company"), and in
response to the First Production Request of the Industrial Customers of Idaho Power to
Idaho Power Company dated May 4, 2011, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 1
REQUEST FOR PRODUCTION. NO.1: Please provide in electronic format
Exhibits 1, 2, and 3 that were part of Matthew T. Larkin's Direct Testimony filed in this
docket.
RESPONSE TO REQUEST FOR PRODUCTION NO.1: Please see the
enclosed CD for the electronic files. Please note that the rates provided in Exhibit No.2
(Attachment 2) included on the enclosed CD do not exactly match those provided in
Exhibit No. 2 of the Company's initial filing. In the original exhibit, rates calculated in
column 4 were rounded to align with the authorized collection of $10 milion of the rider
deferral balance. In order to provide an exhibit "in electronic format," Exhibit No. 2 on
the enclosed CD does not reflect this rounding adjustment.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst I, Idaho Power Company, in consultation with Donovan E. Walker, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 2
REQUEST FOR PRODUCTION NO.2: Please provide all documents,
workpapers, and electronic spreadsheet that have been provided to the Idaho Public
Commission Staff in Case No. IPC-E-11-06 including the Company's Responses to the
Commission's Staff audit request.
RESPONSE TO REQUEST FOR PRODUCTION NO.2: Idaho Power hereby
objects to the Industrial Customers of Idaho Powets ("ICIP") Request for Production
No.2. The Idaho Public Utilties Commission ("Commission") Staffs audit requests are
conducted pursuant to the Commission's right of statutory examination and audit, which
exists for the Commission, an individual Commissioner, or an authorized member of the
Commission Staff, and not for other parties to formal proceedings. Rule 227; Idaho
Code § 61-610. The Commission's right of statutory examination and audit entitles the
Commission to examine and audit materials that may not be appropriate for other
parties to formal proceedings. Id., Idaho Code §§ 61-401,61-402,61-403,61-404,61-
405, 61-505, 61-611, and 61-1003. Please identify what specific information ICIP
requests, as was done above in Request for Production No.1, and if appropriate for
Idaho Power to do so, Idaho Power wil so answer and/or present a protective
agreement for execution if required for the disclosure of confidential information.
The response to this Request was prepared by Donovan E. Walker, Lead
Counsel, Idaho Power Company.
DATED at Boise, Idaho, this 18th day of May 2011.
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DONOVAN E. WALKER
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 18th day of May 2011 I served a true and correct
copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER upon the
following named parties by the method indicated below, and addressed to the following:
Commission Staff
Donald L. Howell, "
Deputy Attorney General
Idaho Public Utiities Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
-- Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email Don.Howell(qpuc.idaho.gov
Industrial Customers of Idaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON & O'LEARY, PLLC
515 North 2ih Street
P.O. Box 7218
Boise, Idaho 83702
Hand Delivered
-- U.S. Mail
_ Overnight Mail
FAX
-- Email peter(qrichardsonandoleary.com
greg(qrichardsonandoleary.com
Dr. Don Reading
6070 Hil Road
Boise, Idaho 83703
Hand Delivered
-- U.S. Mail
_ Overnight Mail
FAX
-- Email dreading(qmindspring.com
c£ýc(~Donovan E. Walker
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 4