20130321IPC to IIPA 1-16.pdf

IDAHO
An IDACORP Company
P11 t:29
LISA D. NORDSTROM
Lead Counsel
Inordstromidahopower.com
March 21, 2013
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83702
Re: Case No. IPC-E-12-29
Temporary Suspension of Demand Response Programs - Idaho Power
Company's Response to the Idaho Irrigation Pumpers Association, Inc.'s,
("II PA") First Production Request
Dear Ms. Jewell:
Enclosed for filing in the above matter are an original and three (3) copies of Idaho
Power Company's response to IIPA's First Production Request.
Also enclosed are four (4) copies of the non-confidential disk and four (4) copies of
a confidential disk containing data responsive to IIPA's Request. Please handle the
confidential information in accordance with the Protective Agreement executed in this
matter.
Very truly yours,
cx~~ s4at~~~
Lisa D. Nordstrom
LDN:evp
Enclosures
1221 W. Idaho St. (83702)
P.O. Box 70
Boise, ID 83707
r
LISA D. NORDSTROM (ISB No. 5733)
JULIA A. HILTON (ISB No. 7740)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
Inordstromidahopower.com
jhiIton(ãidahopower.com
Attorneys for Idaho Power Company
2C!flR21 PM I:29
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO TEMPORARILY
SUSPEND ITS A/C COOL CREDIT AND
IRRIGATION PEAK REWARDS
DEMAND RESPONSE PROGRAMS.
CASE NO. IPC-E-12-29
IDAHO POWER COMPANY'S
RESPONSE TO THE IDAHO
IRRIGATION PUMPERS
ASSOCIATION, INC.'S, FIRST
PRODUCTION REQUEST
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in
response to Idaho Irrigation Pumpers Association, Inc.'s, ("IIPA") First Production
Request to Idaho Power Company dated February 28, 2013, herewith submits the
following information:
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST PRODUCTION REQUEST -1
REQUEST NO. 1: Please provide actual monthly sales and customer count data
for each customer grouping in Oregon and Idaho from January 2005 through the most
recent month available. Please supply monthly wholesale sales data as well.
RESPONSE TO REQUEST NO. 1: Please see the Excel file provided on the
non-confidential CD that contains the requested monthly sales and customer count data
for the time period January 2005 through December 2012. Please note the sales for
resale values reflect physical sales for resale, and exclude financial sales, exchanges,
and physical losses. Sales information for January and February of 2013 is not yet
publicly available.
The response to this Request was prepared under the direction of Tami White,
Rate Design Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom,
Lead Counsel, Idaho POwer Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST PRODUCTION REQUEST -2
REQUEST NO. 2: Please supply in electronic format for each month since
January 2008 the billing month normalized billing determents [sic] (and associated
revenue) of each of the rate categories in the Oregon jurisdiction.
RESPONSE TO REQUEST NO. 2: Historical billing determinants are provided
in electronic format for 2008 through 2012 in the confidential Excel file provided on the
confidential CD. The confidential CD will be provided to those parties that have
executed the Protective Agreement in this proceeding. Please note that these detailed
monthly billing determinants reflect weather normalized usage and are prepared for the
specific purpose of deriving normalized test year retail revenues. Revenue associated
with each category of billing determinant reflects annualized historical rates in effect as
of December 31 of each historical year applied to normalized billing determinants.
The response to this Request was prepared by Matthew Larkin, Regulatory
Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST PRODUCTION REQUEST -3
REQUEST NO. 3: Please provide from January 1, 2010 through the most recent
data available, hourly data similar to that provided in response to Irrigator Request 8 in
Case IPC-E-1 1-08. In addition, please provide a breakout of each of the Company's
gas fired units.
RESPONSE TO REQUEST NO. 3: This response is in the same format as was
provided in Idaho Power's response to Irrigator Request No. 8 in case No. IPC-E-1 1-08.
There is one workbook for 2010 with monthly tabs, one for 2011, and one for 2012.
There are drop down menus on line 6 which allow filtering of the data. For instance,
clicking on the arrow on line 6 of Column A allows you to see the drop-down menu for
system load data. Selecting "system load" from the menu will bring up the system load
data starting in column R and continuing to column AW on an hourly basis. Please see
the Excel files (Attachments 1, 2, and 3) provided on the non-confidential CD. The
specific Request No. 3 responses (3.a to 3.v) are identified by the column headings on
line 5 as shown below.
RESPONSE TO REQUEST NO. 3.a - v:
a.Total system input; use column Q.
b.System input from Company owned generation (stating hydro, coal, and
other generation separately); use column P. In prior years the "other" category was
actually the gas fired units, so this data will show "gas" instead of "other".
C. System input from firm purchases, stating each purchase separately by
source and type of purchase (LF, IF, SF, etc.) and
d. The cost of each firm purchase listed in 3.c above; use column 0. The
cost will show in column V.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST PRODUCTION REQUEST -4
e.System input from non-firm and/or economy purchases, stating each
purchase separately and
f.The cost of each non-firm and/or economy purchase listed in 3.e above;
use column N. The cost will show in column V.
g.System input from exchanges into the system, stating each exchange
separately; use column M.
h.System input from unit purchases; use column L.
i.Other system inputs, stating for each "other" input the type and the source
of the input; use column K.
j.Jurisdictional (Idaho and Oregon) sales; this data is unavailable on an
hourly basis.
k.System losses; use column J.
I. See response below (prepared by others).
M. Long-term firm Wholesale sales (LF), stating each one separately; use
column I.
n.Intermediate-term firm Wholesale sales (IF), stating each one separately;
use column H.
o.Short-term Wholesale sales (SF), stating each one separately; use column
G.
P. Unit sales, Wholesale (LU) or otherwise, stated separately; use column F.
q.Non-firm and/or economy Wholesale sales (OS), stated separately and
r.The revenue collected each hour from each non-firm and/or economy
purchase listed in 3.p above; use column E.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST PRODUCTION REQUEST -5
S. Exchanges out of the system, stating each exchange separately; use
column D.
t. Other system outputs, stating for each "other' output the type and
recipient of the output; use column C.
U.Inadvertent power flows into or out of the system; use column B.
V.The power available (at input level) to supply retail load once Wholesale,
Exchange, Wheeling, and Inadvertent have been subtracted; use column A.
The response to this Request was prepared under the direction of Matthew
Larkin, Regulatory Analyst II, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
RESPONSE TO REQUEST NO. 3.1:
I. Requirements Wholesale sales (RQ).
The contract for hourly long-term firm wholesale sales expired September 30,
2011. The Company does not currently have any long-term firm wholesale (RQ)
contracts. Please see the confidential Excel file (Attachment 4) provided on the
confidential CD. The confidential CD will be provided to those parties that have
executed the Protective Agreement in this proceeding.
The response to this Request was prepared by Mary Arnold, Load Research
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
RESPONSE TO REQUEST NO. 3.w:
W.Losses assigned to each retail jurisdiction.
Hourly losses assigned to each retail jurisdiction are not available. Loss factors
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST PRODUCTION REQUEST -6
for peak demand and energy by voltage for each jurisdiction are contained in the
"RefTables" tab of the confidential Excel files (Attachments 5, 6, and 7) provided on the
confidential CD. The confidential CD will be provided to those parties that have
executed the Protective Agreement in this proceeding. These are system loss factors
by voltage level and are not calculated on an hourly basis.
The response to this Request was prepared by Mary Arnold, Load Research
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
RESPONSE TO REQUEST NO. 3.x:
X.Losses assigned to Wholesale sales.
Hourly losses assigned to wholesale sales are not available. Loss factors for
peak demand and energy by voltage are contained in the "RefTables" tab of the
confidential Excel files (Attachments 5, 6, and 7) provided on the confidential CD. The
confidential CD will be provided to those parties that have executed the Protective
Agreement in this proceeding. These are system loss factors by voltage level and are
not calculated on an hourly basis.
The response to this Request was prepared by Mary Arnold, Load Research
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
RESPONSE TO REQUEST NO. 3.y:
Y.Total retail load by jurisdiction.
Hourly retail load by jurisdiction is not available. The monthly energy and
coincident demand information for 2010-2012 with and without losses are contained in
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST PRODUCTION REQUEST -7
the confidential Excel files (Attachments 5, 6, and 7) provided on the confidential CD.
The confidential CD will be provided to those parties that have executed the Protective
Agreement in this proceeding.
The response to this Request was prepared by Mary Arnold, Load Research
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST PRODUCTION REQUEST -8
REQUEST NO. 4: How long have all of the Residential customers had AMI
metering?
RESPONSE TO REQUEST NO. 4: The three-year deployment of automated
metering infrastructure ("AMI") was completed in December of 2011. 99.25 percent of
residential customers have had AMI meters installed for 14 months.
The response to this Request was prepared by Mark Heintzelman, Regional
Operations Support Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST PRODUCTION REQUEST -9
REQUEST NO. 5: How long have all of the Irrigation customers had AMI
metering?
RESPONSE TO REQUEST NO. 5: The three-year deployment of AMI was
completed in December of 2011. 93.5 percent of irrigation customers have had AMI
meters installed for 14 months.
The response to this Request was prepared by Mark Heintzelman, Regional
Operations Support Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST PRODUCTION REQUEST -10
REQUEST NO. 6: Please provide on an hourly basis for all summer months
when Residential AMI metering has been available, the combined Residential hourly
load.
RESPONSE TO REQUEST NO. 6: Combined hourly residential load for all
customers is not measured via AMI. Residential customers billing data is captured via
several methods, including AMI as well as monthly-read billing meters. Due to the fact
that not all customers are read via AMI as well as the volume of data, hourly residential
load shapes are determined using load research samples. The Excel file provided on
the non-confidential CD shows the residential hourly mean load shape derived from the
sample and scaled to the customer class.
The response to this Request was prepared by Mary Arnold, Load Research
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST PRODUCTION REQUEST -11
REQUEST NO. 7: Please provide on an hourly basis for all summer months
when Irrigation AMI metering has been available, the combined Irrigation hourly load.
RESPONSE TO REQUEST NO. 7: Combined hourly irrigation load for all
customers is not measured via AMI. Irrigation customers billing data is captured via
several methods including AMI as well as monthly-read billing meters. Due to the fact
that not all customers are read via AMI as well as the volume of data, hourly irrigation
load shapes are determined from load research samples. The Excel file provided on
the non-confidential CD shows the irrigation hourly-mean load shape estimated from the
sample and scaled to the customer class.
The response to this Request was prepared by Mary Arnold, Load Research
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST PRODUCTION REQUEST -12
REQUEST NO. 8: Please provide on an hourly basis for all summer months
when Residential AMI metering has been available, the calculated combined
Residential hourly air conditioning load of those customers that were on the NC Cool
Credit program. Please explain the calculation used to determine the "calculated" air
conditioning load.
RESPONSE TO REQUEST NO. 8: The residential air conditioning load is not
sub-metered so Idaho Power does not have the "calculated" air conditioning load.
The response to this Request was prepared by Pete Pengilly, Customer
Research Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST PRODUCTION REQUEST -13
REQUEST NO. 9: Please provide on an hourly basis for all summer months
when Irrigation AMI metering has been available, the combined Irrigation hourly load of
those customers that were on the Irrigation Peak Rewards Dispatchable Program.
RESPONSE TO REQUEST NO. 9: The combined Irrigation hourly load of all
customers on the Irrigation Peak Rewards Dispatchable Program is not available
because several of the participants are not metered via AMI and several participants do
not have meters which capture interval data. For the approximately 2,346 participant
meters which are read via AMI, the combined hourly load for summer of 2012 is
provided in the Excel file on the non-confidential CD.
The AMI data included in these totals include both normally read interval values
as well as any estimates or un-scaled estimates for intervals that are provided by the
Company's Meter Data Management System algorithms. No distinction or special
handling of the estimated intervals was conducted.
The response to this Request was prepared by Mary Arnold, Load Research
Leader, Idaho Power Company, under the direction of Pete Pengilly, Customer
Research Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST PRODUCTION REQUEST -14
REQUEST NO. 10: Please list for each hour during 2012 when curtailment
occurred for either the Residential, Commercial, or Irrigation customers the
estimated/calculated level of load reduction at both the customer level as well as the
generation level.
RESPONSE TO REQUEST NO. 10: The hourly load reduction for 2012 for
demand response programs at both the generation and customer level is provided in
the Excel file provided on the non-confidential CD.
The response to this Request was prepared by Mary Arnold, Load Research
Leader, Idaho Power Company, under the direction of Pete Pengilly, Customer
Research Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST PRODUCTION REQUEST -15
REQUEST NO. 11: Please provide a copy of the 2004 Summit Blue Consulting,
LLC report that calculates the impact of realized rates of Irrigation load reductions.
RESPONSE TO REQUEST NO. 11: Please see the PDF file of the 2004
Summit Blue Consulting Report provided on the non-confidential CD.
The response to this Request was prepared by Pete Pengilly, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST PRODUCTION REQUEST -16
REQUEST NO. 12: Please provide in electronic format the load research data
used to develop the 2004 Summit Blue Consulting, LLC report.
RESPONSE TO REQUEST NO. 12: Please see the Excel file provided on the
non-confidential CD.
The response to this Request was prepared by Pete Pengilly, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST PRODUCTION REQUEST -17
REQUEST NO. 13: Please provide a copy of any more recent studies of the
realization rates for Irrigation load control.
RESPONSE TO REQUEST NO. 13: Please see the PDF files of the 2005, 2007,
2008, 2009, 2010-2011, and 2012 Irrigation Peak Rewards annual reports (Attachments
I thru 6) provided on the non-confidential CD. Each report contains realization rates for
the program along with a description of the methodology used. A copy of the 2004
Irrigation Peak Rewards annual report is included in Idaho Power's response to IIPA's
Production Request No. 11.
The response to this Request was prepared by Pete Pengilly, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST PRODUCTION REQUEST -18
REQUEST NO. 14: Please provide in electronic format the hourly AMI data for
each Irrigator for the summer of 2012.
RESPONSE TO REQUEST NO. 14: As per the clarification discussion on March
6, 2012, between Eric L. Olsen, Tony Yankel, Mary Arnold, and Lisa Nordstrom, this
response provides 2012 summer hourly interval data for the irrigation load research rate
class sample points. The stratification design of the sample includes stratum weightings,
and indication of which sample points were in the irrigation demand response program.
Please see the Excel file provided on the non-confidential CD.
The response to this Request was prepared by Mary Arnold, Load Research
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST PRODUCTION REQUEST -19
REQUEST NO. 15: For each of the annual peak loads listed in the response to
Staff Request 1, please list the percentage of operating reserves that were held by the
Company, as well as the units and the MW available from each.
RESPONSE TO REQUEST NO. 15: The following data represents the
megawatt ("MW") value of reserves held on Idaho Power's system. Idaho Power is
required to hold 5 percent of the total hydro/wind generation on the system and 7
percent of the thermal generation on the system, as well as sufficient reserve to meet
the fluctuations during the next hour. Idaho Power operates its base load thermal units
and others to ensure sufficient reserves are maintained on units with Automatic
Generation Control to meet these requirements. Specific data regarding the amount of
reserves held on each unit is not available, however, the reserves are most typically
held on the Oxbow and Brownlee generators.
2004 06/24/04 1700 2843 358 355
2005 07/22/05 1600 2961 604 588
2006 07/24/06 1800 3084 355 347
2007 07/13/07 1600 3193 535 535
2008 06/30/08 1500 3214 355 355
2009 07/22/09 2000 3031 541 511
2010 06/28/10 1900 2930 476 470
2011 07/06/11 2000 2973 468 429
2012 07/12/12 1600 3245 539 517
The response to this Request was prepared by Tess Park, Director Load Serving
Operations, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST PRODUCTION REQUEST -20
REQUEST NO. 16: For each of the annual peak loads listed in the response to
Staff Request 1, please list the percentage of spinning reserves that were held by the
Company, as well as the units and the MW available from each.
RESPONSE TO REQUEST NO. 16: The following data represents the MW
value of reserves held on Idaho Power's system. Idaho Power is required to hold 5
percent of the total hydro/wind generation on the system and 7 percent of the thermal
generation on the system, as well as sufficient reserve to meet the fluctuations during
the next hour. 50 percent of those reserves are required to be spinning reserves. Idaho
Power operates its base load thermal units and others to ensure sufficient reserves are
maintained on units with Automatic Generation Control to meet these requirements.
Specific data regarding the amount of reserves held on each unit is not available,
however, the reserves are most typically held on the Oxbow and Brownlee generators.
2004 06/24/04 1700 2843 358 355 296 293
2005 07/22/05 1600 2961 604 588 229 213
2006 07/24/06 1800 3084 355 347 182 174
2007 07/13/07 1600 3193 535 535 303 258
2008 06/30/08 1500 3214 355 355 236 220
2009 07/22/09 2000 3031 541 511 385 355
2010 06/28/10 1900 2930 476 470 407 401
2011 07/06/11 2000 2973 468 429 380 308
2012 07/12/12 1600 3245 539 517 448 331
The response to this Request was prepared by Tess Park, Director Load Serving
Operations, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST PRODUCTION REQUEST -21
DATED at Boise, Idaho, this 21st day of March 2013.
flASA D. NORDSTRbM
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST PRODUCTION REQUEST -22
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on the 21st day of March 2013 I served a true and correct copy
of the within and foregoing IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S, FIRST PRODUCTION REQUEST
upon the following named parties by the method indicated below, and addressed to the
following:
Commission Staff
Donald L. Howell, II
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-0074
Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
201 East Center
P.O. Box 1391
Pocatello, Idaho 83204-1391
Anthony Yankel
29814 Lake Road
Bay Village, Ohio 44140
Idaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 North Sixth Street
Boise, Idaho 83702
X Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email don. howeIkpuc.idaho.ciov
_Hand Delivered
U.S. Mail
_Overnight Mail
FAX
X Email eloracinelaw.net
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email tonycyankel.net
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email botto(idahoconservation.ori
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST PRODUCTION REQUEST -23
Snake River Alliance
Ken Miller, Clean Energy Program Director
Snake River Alliance
P.O. Box 1731
Boise, Idaho 83701
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email kmillercsnakeriveralliance.orq
Elizabdffi Paynter, (al Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST PRODUCTION REQUEST -24
CERTIFICATE OF ATTORNEY
ASSERTION THAT MATERIALS REQUESTED AND PROVIDED DURING THE
COURSE OF AN IDAHO PUBLIC UTILITIES COMMISSION PROCEEDING
ARE PROTECTED FROM PUBLIC INSPECTION
Case No. IPC-E-1 2-29
The undersigned attorney, in accordance with RP 233, hereby certifies that the
attachments provided in Idaho Power Company's responses to the Idaho Irrigation
Pumpers Association, Inc.'s, Production Request Nos. 2 and 3 contain information that
is a trade secret or privileged or confidential as described in Idaho Code § 9-340, et
seq., and § 48-801, et seq., and as such are exempt from public inspection,
examination, or copying.
DATED this 21st day of March 2013.
rxlZak- J9.
Lisa D. Nordstrom(
Lead Counsel for Idiho Power Company
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