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HomeMy WebLinkAbout20110519IPC to ICIP 1-2.pdfDONOVAN E. WALKER Lead Counsel dwalkertâidahopower.com RECE.\\ lM ~: 5\ isIDA~POR4i 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. y;cltL Donovan E. Walker DEW:csb 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. dLfdJ~ 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