20150420ICIP 1-7 to IPC.pdf

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
gre [e-mail]
Attorneys for the lndustrial Customers of ldaho Power
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR AUTHORITY TO
TMPLEMENT POWER COST
ADJUSTMENT MECHANISM ("PCA")
RATES FROM JUNE I,2OI5 THROUGH
MAY 3t,2016.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
) CASE NO. rPC-E-rs-I4
)) FTRST PRODUCTION REQUEST OF
) THE INDUSTRIAL CUSTOMERS OF
) IDAHO POWER
)
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), The Industrial Customers of Idaho Power ("ICIP") by and through their
attorney of record, Peter J. Richardson, hereby requests that ldaho Power Company
("Company") provide the following documents.
This production request is to be considered as continuing, and the 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 one physical copy and one electronic copy, if available, of your answer to
Mr. Richardson at the address noted above. Please provide an additional electronic copy, or if
unavailable a physical copy, to Dr. Don Reading at: 6070 Hill Road, Boise, Idaho 83703, Tel:
[phone]; Fax: (208) 3 84- I 5 I I ; [e-mail]
For each item, please indicate the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness at hearing who can sponsor the answer.
REOUEST FOR PRODUCTION NO. I
Please provide a working electronic copy of Exhibit No. I to Scott Wright's testimony.
REOUEST FOR PRODUCTION NO. 2
Please provide a working electronic copy of Exhibit No. 2 to Scott Wright's testimony.
REOUEST FOR PRODUCTION NO. 3
Please provide a working electronic copy of Exhibit No. 3 to Kelley Noe's testimony.
REOUEST FOR PRODUCTION NO. 4
Please provide a working electronic copy of Exhibit No. 4 to Kelley Noe's testimony.
REOUEST FOR PRODUCTION NO. 5
Please provide a working electronic copy of Attachment No. 2 to Idaho Power's
Application.
REOUEST FOR PRODUCTION NO. 6
Please provide copies of Idaho Power's responses to discovery requests by all other
parties to this docket.
REOUEST FOR PRODUCTTON NO. 7.
Please provide copies of all documents, information and material informally exchanged
between the IPUC Staffand Idaho Power that is not otherwise provided pursuant to the
ICIP's other production requests.
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FIRST PRODUCTTON REQUEST OF THE TNDUSTRIAL CUSTOMERS OF IDAHO
POWER
rPC-E-15-14
PAGE 2
DATED this 20tr day of April,2}ll
Richardson Adams, PLLC
Nina Curtis
Administrative Assistant
FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER
IPC-E-15-14
PAGE 3
CERTIFICATE OF SERVICE
I hereby certii/ that on April 20, 2015, copies of the foregoing First Production Request
of the Industrial Customers of Idaho Power in Docket No. IPC-E-15-14 was electronically served
and hand delivered to:
LisaNordstrom
Regulatory Dockets
Idaho Power Company
1221 West Idaho Street
Boise, Idalro 837 02-007 0
lnordstrom@ idahopower. com
dockets@ idahopower. com
Timothy E. Tatum
Gregory W. Said
Idaho Power Company
1221 West Idaho Street
Boise, Idaho 83702-0070
ttatum@ idahopower. com
[e-mail]
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472West Idaho Street
Boise,Idaho 83702
j [e-mail]. gov
Industrial Customers of Idaho Power