20140210Simplot to IPC 1-2.pdf

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Peter J. Richardson ISB # 3195
Gregory M. Adams ISB # 7454
RICHARDSON ADAMS, PLLC
515 N. 27th Street
Boise,Idaho 83702
Telephone : [phone]
Fax: [phone]
peter@richardsonadams. com
greg@richardsonadams. com
Attorneys for the J. R. Simplot Company
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
APPROVAL OF SPECTAL CONTRACT
BETWEEN IDAHO POWER COMPANY
AND J. R. SIMPLOT COMPANY
r-. : t t_:_,ir'' .?: r ILi
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
) CASE NO.IPC-E-13-23
)) J. R. SIMPLOT COMPANY',S
) RESPONSES TO THE FIRST
) PRODUCTION REQUESTS OF
) IDAHO POWER COMPANY
COMES NOW, the J. R. Simplot Company ("Simplot"), and in response to the First
Production Requests of ldaho Power Company to Simplot dated February 7 ,2014, herewith
submits the following answers:
q
REOUEST FOR PRODUCTION NO. 1: Please provide, in electronic format where
possible and with formulas intact, the models and spreadsheets Dr. Reading used to determine
the overall rate for Simplot of 4.441 cents.
RESPONSE TO REOIIEST NO l:The 4.441cents referenced on page 12 of the J. R.
Simplot Answer is a typo, the value is 4.243 cents. Please see the enclosed CD for the
electronic format of Dr. Reading's work.
J. R. SIMPLOT COMPANY RESPONSES TO THE FTRST PRODUCTION
REQUESTS OF IDAHO POWER COMPANY
IPC-E-13-23
PAGE 2
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REOUEST FOR PRODUCTION NO.2: Please provide, in electronic format where
possible and with formulas intact, the models and spreadsheets used to determine Dr. Reading's
substitute results of an overall rate for Simplot of 4.197 cents.
RESPONSE TO REOUEST NO 2: Please see the attached CD. This is the same
spreadsheet "Schedule 33 Rate Design.xlsx" supplied to Dr. Reading by Mike Youngblood
attached to an email on December 3,2013. The values of the average of the three Special
Contract Customers were substifuted for the Schedule 19 values in tab "additional revenue." The
per kWh value of 4.197 cents can be found on tab "Simplot Revenue Requirement."
CERTIFICATE OF SERVICE
I hereby certifr that on 1Oth day of February 2014, copies of the foregoing responses of
the J. R. Simplot Company to Idaho Power Company's First Production Request were delivered
to:
Lisa Nordstrom
Idaho Power Company
1221 West ldaho
Boise,Idaho 83702
Jean Jewel
Secretary
Idaho Public Utilities Commission
472West Idaho
Boise,Idaho 83702
Administrative Assistant
J. R. SIMPLOT COMPANY RESPONSES TO THE FIRST PRODUCTION
REQUESTS OF IDAHO POWER COMPANY
IPC-E-13-23
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