20140227Staff 1-4 to IPC.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
BARNO.6618
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR APPROVAL
OF A SPECIAL CONTRACT WITH J.R.
SIMPLOT COMPANY.
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CASE NO. IPC.E.13.23
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Kristine A. Sasser, Deputy Attorney General, requests that Idaho Power Company (Company)
provide the following documents and information on or before THURSDAY, MARCH20,20[4.
This Production Request is to be considered as continuing, and Idaho Power Company is
requested to provide, by way of supplementary responses, additional documents that it or any person
acting on its behalf may later obtain that will augment the documents produced.
Please provide answers to each question and any supporting workpapers that provide detail or
are the source of information used in calculations. The Company is reminded that responses pursuant
to Commission Rules of Procedure must include the name and phone number of the person preparing
the document, and the name, location and phone number of the record holder and if different the
witness who can sponsor the answer at hearing. Reference IDAPA 31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY I FEBRUARY 27,2014
REQUEST NO. 1: Please provide the actual load factors for 201 1,20t2 and2013 by month
for Schedule 19, Micron, Simplot (Pocatello) and DOE. Provide them in a format similar to the load
factor calculations on the "usage" tab in file "Schedule 33 Rate Design.xlsx" that the Company
provided to Simplot.
REQUEST NO. 2: Please provide load factors for the same time period and in the same
format for the three plants that Simplot intends to close.
REQUEST NO. 3: What have the loads and load factors been at the new facility in Caldwell
since it began operations? Provide the information in the format specified in Production Request
No. 1.
R-EQUEST NO. 4: When is the load at the new facility expected to exceed 20 MW?
Dated at Boise, Idaho, thi, 214ay of Febru ary 2014.
Technical Staff: Keith Hessing
i:umisc:prodreq/ipce I 3.23kskh prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY
KriJtine A. Sasser
Deputy Attorney General
FEBRUARY 27,2014
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 27TH DAY OF FEBRUARY 2014,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
CoMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
IPC-E-13.23, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
LISA D NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL : [e-mail]
PETER J RICHARDSON
GREGORY M ADAMS
RICHARDSON ADAMS PLLC
5I5 N 27TH STREET
BOISE ID 83702
E-MAIL : [e-mail]
gre [e-mail]
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CERTIFICATE OF SERVICE