20110630Kroger Q1-1 - Q1-2 to IPC.pdf

VIA OVERNGHT MA
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
P.O. Box 83720
472 W. Washington Street
Boise, Idaho 83720-0074
In re: Case No. IPC-E-ll-08
Dear Ms. Jewell:
BOEHM, KURTZ & lOWRY
ATIORNS AT lAW36 EAT SEV STRET R E C E f V E 0
SUITE 1510
CINCINNATI, OHIO 45202
TELEHONE [phone] ior I JUN 30 PH 2= 33
TELECOPlER [phone]
June 28, 201 i
Enclosed please find the original and (7) copies of the FIRST SET OF INTERROGATORIS OF THE
KROGER CO. to IDAHO POWER COMPAN to be fied in the above referenced matter.
Please place this document of fie. Copies have been served on all parties listed on the attached
Certificate of Service.
KJBkew
EncL.
R~e;rn,
Kurt J. Boehm, Esq.
BOEHM, KURTZ & LOWRY
G:\WORK\MLK\KROGER\IDAHO\IPC-E-II-08\Commission Data Request letter.docx
CERTIFICATE OF SERVICE
I hereby certify that tre copy of the foregoing was served by overnight mail, unless otherwse noted, this
28th day of June, 201 i to the following:
Lisa D. Nordstrom
Jason B. Wiliams
IDAHO POWER COMPANY
P.O. Box 70
Boise, ID 83707-0070
Donavan Walker
Greg Said
IDAHO POWER COMPANY
P.O. Box 70
Boise, ID 83707-0070
G:\WORK\MLK\KROGER\IDAHO\IPC-E-II-08\Commission Data Request letter.docx
~
Kurt J. Boehm, Esq.
Eric L. Olsen
RACINE OLSON NYE BUDGE & BAILEY, CHTD.
20 i E. Center
P.O. Box 1391
Pocatello,ID 83204-1391
Anthony Yankel
29814 Lake Rd.
Bay Vilage, OH 44140
John R. Hammond, Jr., ISB No. 5470
BATT FISHER PUSCH & ALDERMAN, LLP
U.S. Ban Plaza, 5th Floor
101 S. Capitol Boulevard, Suite 500
P.O. Box 1308
Boise, Idaho 83701
Telephone: [phone]
Facsimle: 208.331.2400
E-mail: jrht§battfisher.com
Kur J. Boehm
BOEHM, KURTZ & LOWRY
36 E. Seventh St., Suite 1510
Cincinati, Ohio 45202
Telephone: [phone]
Facsimle: 513.421.2764
E-mail: KBoehm(fbk11awfir.com
Attorneys for Kroger Co.
RECEIVED
zon JUN 30 PH 2= 33
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPAN FOR )
AUTHORITY TO INCREASE ITS RATES )
AN CHAGES FOR ELECTRIC SERVICE TO )
ITS CUSTOMERS IN THE STATE OF IDAHO )
)
)
Case No. IPC-E-11-08
FIRST SET OF INTERROGATORIS OF
KROGER CO. TO IDAHO POWER
COMPANY
FIRST SET OF INTERROGATORIS OF
THE KROGER CO.
TO IDAHO POWER COMPAN
June 28, 2011
DEFINITIONS
1. "Document" means the original and all copies (regardless of origi and whether or not includig
additional wrting thereon or attached thereto) of memoranda, reports, books, manuals, instrctions,
directives, records, forms, notes, letter, notices, conftions, telegrain, pamphlets, notations of any
sort concerng conversations, telephone calls, meetings or other communcations, bulletins, trascripts,
diares, analyses, sumaries, correspondence investigations, questionnaires, sureys, worksheets, and ail
drafts, prelimiary versions, alterations, modifications, revisions, changes, amendments and written
comments concernng the foregoing, in whatever form, stored or contained in or on whatever medium,
includig computerized memory or magnetic media.
2. "Study" means any written, recorded, transcribed, taped, filmed, or grphic matter, however produced or
reproduced, either formally or informally, a paricular issue or sitution, in whatever detail, whether or
not the consideration of the issue or situation is in a prelimiary stage, and whether or not the
consideration was discontinued prior to completion.
3. "Person" means any natual person, corporation, professional corporation, parnership, association, joint
venture, proprietorship, firm, or the other business enterprise or legal entity.
4. A request to identify a natual person meas to state his or her ful nae and residence address, his or her
present last known position and business affliation at the time in question.
5. A request to identify a document mean to state the date or dates, author or origiator, subject matter, all
addressees and recipients, tye of document (e.g., letter, memorandum, telegram, cha, etc.), number of
code number thereof or other means of identifyg it, and its present location and custodian. If any such
document was, but is no longer in the Company's possession or subject to its control, state what
disposition was made of it.
6. A request to identify a person other than a natural person means to state its full name, the address of its
principal offce, and the type of entity.
7. "And" and "or" should be considered to be both conjunctive and disjunctive, uness specifically stated
otherise.
8. "Each" and "any" should be considered to be both singular and plural, uness specifically stated
otherwise.
9. Words in the past tense should be considered to include the present, and words in the present tense
include the past, uness specifically stated otherwise.
10. "You" or "your" means the person whose fied testimony is the subject of these interrogatories and, to the
extent relevant and necessar to provide ful and complete answers to any request, "you" or "your may
be deemed to include any person with informtion relevant to any interrogatory who is or was employed
by or otherise associated with the witness or who assisted, in any way, in the preparation of the witness'
testimony.
11. Idaho Power Co. ("Company") means any of their offcers, directors, employees, or agents who may have
knowledge of the paricular matter addressed.
INSTRUCTIONS
1. If any matter is evidenced by, referenced to, reflected by, represented by, or recorded in any document,
please identify and produce for discovery and inpection each such document.
2. These interrogatories are continuing in natue, and informtion which the responding party later becomes
aware of, or has access to, and which is responsive to any request is to be made available to Fred Meyer
Stores, studies, documents, or other subject matter not yet completed that wil be relied upon durng the
course of this case should be so identified and provided as soon as they are completed. The Respondent is
obliged to change, supplement and correct all anwers to interrogatories to conform to available
information, including such informtion as it first becomes available to the Respondent after the answers
hereto are served.
3. Unless otherwise expressly provided, each interogatory should be construed independently and not with
reference to any other interrogatory herein for purose of limtation.
4. The answers provided should first restate the question asked and also identify the person(s) supplying the
information.
5. Please answer each designated par of each information request separately. If you do not have complete
information with respect to any interrogatory, so state and give as much informtion as you do have with
respect to the matter inquied about, and identify each person whom you believe may have additional
information with respect thereto.
6. In the case of multiple witnesses, each interrogatory should be considered to apply to each witness who
wil testify to the information requested. Where copies of testimony, transcripts or depositions are
requested, each witness should respond individualy to the informtion request.
7. The interogatories are to be answered under oath by the witness( es) responsible for the anwer.
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FIRST SET OF INTERROGATORIES OF
THE KROGER CO. TO
IDAHO POWER COMPAN
CASE NO. IPC-E-ll-08
Q1.1. Please send our consultant Kevin Higgins a complete hard copy of IDAHO POWER COMPAN'S
Application and Direct Testimony as well as copies of all past and future data responses provided by
IDAHO POWER COMPAN to data requests submitted by other paries in ths case. Please provide
your responses to our consultant at the address listed below.
Q 1.2. Please provide an electronic version of all workpapers with formulas in tact in excel formt and forward
to our consultant at the address listed below.
Kevin Higgins
Energy Strategies, LLC
Parkside Towers
215 South State Street, Suite 200
Salt Lae City, Utah 84111
khgginst§energystrat.com
Respectfuly submitted,l¿~
Kur J. Boehm Esq.
BOEHM, KURTZ & LOWRY
36 East Seventh Street, Suite 1510
Cincinati, Ohio 45202
Ph: [phone] Fax: [phone]
E-mail: kboehmt§BKLlawfirm.com